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  • MIPS 2020—Bonuses and Penalties

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    This content is excerpted from EyeNet’s MIPS 2020; also see the Academy’s MIPS hub page.

    Based on your 2020 MIPS final score, CMS will apply a payment adjustment to your 2022 Medicare Part B payments.

    CMS continues to raise the bar. To avoid a payment penalty in 2022, you need a 2020 MIPS final score of at least 45 points (up from 30 points in 2019); to earn an exceptional performance bonus, you need to score at least 85 points (up from 75 points in 2019).

    Table: Bonuses and Penalties

    2020 MIPS Final Score 2022 Payment Adjustment
    0-11.25 points Maximum penalty of –9%
    11.26-44.49 points Penalty on a sliding scale (see table below)
    45 points Neutral (no penalty, no bonus)
    45.01-84.99 points Initial bonus*
    85-100 points Initial bonus* + exceptional performance bonus†

    * The initial bonus is based on a linear sliding scale—those who score 45.01 points get the lowest bonus; those who score 100 points get the highest.

    † The exceptional performance bonus is based on a linear sliding scale—those who score 85 points get the lowest bonus; those who score 100 points get the highest.

    Potential penalties are higher. The maximum payment penalty has increased to –9% (up from –7% for the 2019 performance year/2021 payment year).

    Table: Payment Penalty

    If your 2020 MIPS final score is less that the 45-point performance threshold, your 2022 Medicare Part B payments will be reduced as shown below.

    Table: Payment Penalty for MIPS performance year 2020/payment year 2022Although CMS has set the negative payment adjustment (as shown above), it doesn’t yet know what the positive payment adjustments will be. The bonus for scoring more than 45 points (the initial bonus) will be funded by payment penalties. Consequently, CMS won’t be able to estimate how much money is in the bonus pool—and how many clinicians will be entitled to money from that pool—until it has calculated the MIPS final scores of all MIPS participants, which can’t happen until the performance year is over. Similarly, until CMS knows how many MIPS eligible clinicians have scored at least 85 points, it won’t know how far it has to stretch the $500-millon bonus pool for exceptional performance. 

    Why is there a gap year between performance (2020) and payment adjustments (2022)? CMS needs time to process the MIPS data, determine final scores, perform targeted reviews, and calculate an adjustment factor that ensures budget neutrality.

    How the Bonuses and Penalties Will Be Applied

    You can report and be scored as an individual and/or as part of a group. If you are scored as an individual, CMS will use both your Tax Identification Number (TIN) and National Provider Identifier (NPI) to distinguish you as a unique MIPS participant. If you and your colleagues report as a group, the group’s TIN will be used as your identifier for scoring purposes. You also can report both ways and see which approach scores higher (see “Participate as an Individual or as a Group?”).

    Payment adjustments are always applied at the TIN/NPI level. CMS will apply the payment adjustments at the TIN/NPI level, regardless of whether you were assigned a MIPS final score as an individual or as part of a MIPS group.

    Your 2020 final score will follow you to your next practice. Your 2020 final score will determine your 2022 payment adjustment, and this is the case even if you move to a new practice after the 2020 performance year is over. 

    The payment adjustments will be applied throughout the year. CMS will start applying the MIPS payment adjustments in 2022. They will be applied throughout the year to your Medicare Part B remittances.

    Table: How the Bonuses Are Funded

    2020 MIPS Final Score

    2022 Payment Adjustment

     

    Provenance of Bonus Dollars

    0-11.25 points

    –9% penalty (negative payment adjustment)

    →

    The negative payment adjustments reduce CMS expenditure. These savings go into a bonus pool that funds the initial bonuses (which are therefore budget neutral).

     

     

     

    These initial bonuses are paid on a linear sliding scale. (Those who score 45.01 points get the lowest bonus, those who score 100 points get the highest.)

    11.26-44.99 points

    Payment penalty on a linear sliding scale, as shown in Table 15 (negative payment adjustment)

    →

    45 points

    Neutral (no payment adjustment)

    		  

    45.01-84.99 points

    Initial bonus (payment adjustment)

    ←

    85-100 points

    Initial bonus (payment adjustment)

    ←

    + exceptional performance bonus (additional payment adjustment)

    ←

    		 Funded by a separate $500-million bonus pool, these exceptional performance bonuses are paid on a linear sliding scale. (Those who score 85 points get the lowest bonus, those who score 100 points get the highest.)

    Previous: Performance Periods

    Next: Who Does (and Doesn’t) Take Part in MIPS

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